New to the forum!!!!

Hi Guys! Just wanted to say hello and to give a big compliment. I have been reading alot of the posts and have seen a lot of good advice being given. You all should pat yourself on the back. Congratulations and the work you have been doing. TraneTech1 40 yrs seasoned tech. Currently a "Applied Systems Specialist Technician" with an independent Trane office.

New to the forum!!!!

Awesome, another well seasoned tech I can hound for answers.

What's your take on the EPA regulation concerning changing out just the condenser, dry charged, and using new R-22? Legal? I guess the real question is if just changing the condenser is considered a system service/repair which would mean that new refrigerant is legal versus using reclaimed. And if the old compressor is a burn out than we can't use that refrigerant anyways so..?

New to the forum!!!!

Hi Doc,
Going through your question and it is a good one. The problem I have is I rarely work on anything less than 200 tons. I use to have my on residential/ light commercial business when I was in another state (that is a whole different story). I don't get into the codes and EPA restrictions for residential so I am unable to answer your question. Sorry about that. However, the diagnostics and troubleshooting of any refrigerant/control system is essentially the same no matter the tonnage. That is where I can be of further assistance. Thanks for the welcome guys, and look forward to working with such an elite group of technicians!

New to the forum!!!!

Not going to see questions on anything but residential systems here but the debate was, concerning an EPA regulation, that only when servicing/repairing an existing system can you add new refrigerant versus recovered/reclaimed and thus whether or not changing out just the condenser alone would be considered just a repair of an entire system. I think so as I know no company that uses reclaimed refrigerant on just a single piece of the whole system changeout, single piece being evaporator or condenser. Btw, I've been doing this for over a decade.

Another question arose, whether a compressor and a condenser would be considered the same thing. I think so as with Amana high seer condensing units if a compressor fails under warranty then they will not just give out a compressor but rather an entire new condensing unit. I think that regardless of that fact the two should be considered for the most part one and the same.

Neither compressors or condensers, which would be for R-22 systems in this debate, come with said refregerant in them.

New to the forum!!!!

Quote:

Originally Posted by Doc Holliday

Not going to see questions on anything but residential systems here but the debate was, concerning an EPA regulation, that only when servicing/repairing an existing system can you add new refrigerant versus recovered/reclaimed and thus whether or not changing out just the condenser alone would be considered just a repair of an entire system. I think so as I know no company that uses reclaimed refrigerant on just a single piece of the whole system changeout, single piece being evaporator or condenser. Btw, I've been doing this for over a decade.

Another question arose, whether a compressor and a condenser would be considered the same thing. I think so as with Amana high seer condensing units if a compressor fails under warranty then they will not just give out a compressor but rather an entire new condensing unit. I think that regardless of that fact the two should be considered for the most part one and the same.

Neither compressors or condensers, which would be for R-22 systems in this debate, come with said refregerant in them.

Thoughts while we wait for the EPA to call me back?

After all your whining about wanting your thread deleted you bring it back up here.......

The EPA is a bit confusing....

1.) Under the allocation rule, virgin HCFC–22 or HCFC–142b may only be used to service existing appliances. Virgin HCFC–22 and HCFC–142b may not be used to manufacture new precharged appliances and appliance components. Virgin HCFC–22 and HCFC–142b also may not be used to charge new appliances assembled onsite on or after January 1, 2010, though new appliances (not pre-charged) may be charged with reclaimed refrigerant.

2.)Consistent with decisions made in the 1993 rule, EPA is applying the section 605(a)(3) exception such that virgin HCFC–22 and HCFC–142b, and blends containing HCFC–22 or HCFC–142b, may be used for servicing and maintenance of appliances manufactured before 2010 but may not be used in the manufacture of equipment after January 1, 2010. EPA is taking this action under the authority of section 606 of the Clean Air Act. EPA notes that allowable servicing could entail a wide range of activities including replacing parts or components. Per the accompanying Pre-Charged Appliances rule, these parts and components may contain HCFCs
(including virgin material) if manufactured prior to January 1, 2010, but must be shipped without HCFC (i.e. dry or with a nitrogen holding charge) if manufactured after January 1, 2010.

3.)Appliances are separate from components, which are the individual parts of an appliance, such as a condensing unit or line set, that by themselves cannot function to provide a cooling effect. In considering the meaning of ‘‘manufactured,’’ EPA has considered the definition of appliance carefully, particularly evaluating at what point a group of components become a manufactured appliance. In the final rule, EPA is providing a definition of the term ‘‘manufactured.’’ This definition can also be found in the companion Pre-Charged Appliances rule. The term manufactured ‘‘for an appliance, means the date upon which the appliance’s refrigerant circuit is complete, the appliance can function, the appliance holds a full refrigerant charge, and the appliance is ready for use for its intended purposes; and for a pre-charged appliance component, means the date that such component is completely produced by the original equipment manufacture, charged with refrigerant, and is ready for initial sale or distribution in interstate commerce.’’

4.)Pre-charged components manufactured before January 1, 2010, may be used to service appliances manufactured before January 1, 2010, but may not be assembled to create new appliances unless there is no use of virgin HCFC–22 or HCFC–142b, in the components or otherwise. The allocation rule prohibits use of virgin HCFC–22 and HCFC–142b in manufacturing new appliances.

SO, from everything that I have read (which was a LOT). Because your condensing unit is a component used in repair of an existing appliance that was manufactured before Jan 1, 2010 you are perfectly legal to use virgin R22.

New to the forum!!!!

Most of what that site says, is before the final rulings. And it even tries to apply the commercial and industrial rules to residential equipment.

Any owner of cooling equipment which uses more than 50lbs of freon must repair all found leaks within 30 days of notice. Exceptions to this rule do exist and can be found on the Environmental Protection Agency website. This applies to commercial and industrial only.

All HVAC equipment using more than 2,000 lbs of freon must install a special system that will detect leaks immediately. It is law that this equipment be monitored, maintained, and all details be reported.

As of January 1, 2010 it is illegal to charge any residential hvac equipment manufactured after January 1, 2010 with R-22 freon. Units manufactured before that date can still be charged with R-22 if serviceable. If unserviceable, they may be replaced from the manufacturers existing inventory of unused/unsold units if available, of R22 refrigerant units manufactured before January 1, 2010 or the newer units manufactured after January 1, 2010 which utilize R410a freon. Units manufactured after January 1, 2010 for residential use may only be charged with R410a freon if a leak occurs. False

HVAC units purchased and installed prior to 2010 may be recharged under strict guidelines. Half truth

All activity with freon must be recorded and reported to the Environmental Protection Agency by the technician or wholesaler. 50% BS.